- 13 - day notification period. These time periods were met in this appeal. IRC 6330(c) allows the taxpayer to raise any relevant issue relating to the unpaid tax or the NFTL or Notice of Intent to Levy at the hearing. This Appeals Officer has had no prior involvement with respect to these appealed liabilities. 2. Issues raised by the taxpayer; Underlying liability or amount of liability Taxpayer is disputing the tax liability. In cases where the Department of Justice (DOJ) have previously reduced a liability to judgment Appeals has no author- ity to compromise a liability or reconsider the liabil- ity issue which includes taxpayer’s challenge to the collection statute of limitations. Further, Appeals does not have the authority to consider any offer involving the release of federal tax liens or withdraw- als. Accordingly, since DOJ has previously reduced this taxpayer’s liability to judgment, Appeals does not have authority to consider the liability issue. The underlying liability is sustained. Collection Alternatives Taxpayer did not propose any acceptable collection alternatives. When the Notice of Federal Tax Lien was filed it was appropriate. The liability was valid and outstanding. 3. Balancing of need for efficient collection with taxpayer concern that the collection action be no more intrusive than necessary. We believe the filing of the Notice of Federal Tax Lien balances the need for efficient collection of taxes with concerns that the collection action be no more intrusive than necessary. [Reproduced literally.] Petitioner filed a petition with the Court with respect to the notice of determination. The petition contained statements,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011